April 2, 2021
Interim State Superintendent of Education
Office of the State Superintendent of Education
1050 First Street, NE
Washington, DC 20002
Dear Interim Superintendent Young:
We are writing to submit public comments in response to the Office of the State Superintendent’s (OSSE) one-year waiver request of statewide assessments, accountability, school identification, and reporting as required by the Elementary and Secondary Education Act of 1965 (ESEA), and amended by the Every Student Succeeds Act of 2015 (ESSA).
Statewide summative assessments are essential for advancing racial equity
Racial equity means “the elimination of racial disparities such that race no longer predicts opportunities, outcomes or the distribution of resources” for DC students, particularly for students of color and Black students. In the District of Columbia, we are a long way from that reality. Currently, there are unacceptable racial disparities in graduation rates, attainment of advanced degrees, employment, health outcomes, and life expectancy. Advancing racial equity in DC is urgent and deeply personal for us. We cannot change what we do not measure, and measurement is a key component of racial equity.
Policymakers use statewide summative assessments to provide a baseline understanding of our students’ academic progress to drive programmatic change, direct resources to schools that need them most, and provide critical information on the DC School Report card. A recent poll of parents/guardians who are DC voters commissioned by ERN DC found that an overwhelming majority of parents (87%) surveyed said that end-of-year assessments used to evaluate student learning, skills, and academic achievement are important. Parents/guardians and families want to know whether their children are meeting college- and career-ready expectations and whether our education system responds to and improves their opportunities to succeed. We use statewide summative assessments as unequivocal evidence of longstanding achievement gaps and racial disparities in academic opportunity so that we can advocate for system wide change.
Flexibilities are needed but these six equity guardrails must be in place
For the past year, our students, families, and school communities in DC have been grappling with Coronavirus Disease 2019 (COVID19) challenges of illness, death, job loss, social isolation, and daily disruptions. Black, Brown, Immigrant, and low-income families have borne the worst of those impacts. Our school leaders and educators have performed miracles to ensure learning continues under challenging scenarios. Yet schools remain shuttered or under-enrolled. Many students continue to learn virtually, which reduces quality time spent with their friends, educators, and school staff, burdens families, and impacts learning. Some students are not participating in remote learning and continue to, or have become, disengaged from learning this school year. As a consequence, many students’ academic progress and physical and mental well-being have declined.
Last December, EmpowerK12 released a report revealing an overall loss of four months of learning in math and one month of reading from fall of school year 2019-2020 to fall of school year 2020-2021. The report also found that our at-risk students lost five months of learning in math and four months of learning in reading. Additionally, 77 % of students reported they are concerned that their family will be exposed to COVID-19 and 45% report that their family’s financial situation has become somewhat or significantly more stressful.
Because of learning loss and declines in students’ physical and mental well-being, we believe it is essential for OSSE to ensure these six guardrails are included in its waiver request:
- Ensure local education agencies (LEAs) administer assessments that provide reliable and valid data aligned to the Common Core standards so parents/guardians, educators, and students can have accurate information about how our students are performing academically.
- Ensure LEAs have the support needed to disaggregate and report out data from their local interim assessments by each major racial, ethnic, and immigrant / newcomer group, including by ethnic subgroups within the Asian American and Pacific Islander (AAPI) and Native communities, and other student subgroups – consistent with the requirements of federal law, or going above them to advance equity.
- Make public the plans LEAs submit regarding “local interim assessments to drive instruction, provide additional programmatic interventions, and direct federal Elementary and Secondary School Emergency Relief Fund (ESSER) funding, especially for students most at-risk” so that students, parents/guardians, and the community can know what type of support students should be receiving and can advocate for equitable implementation.
- Provide clear, transparent, and timely “state-provided supports, state provided technical assistance, and oversight through annual monitoring and oversight activities.” Now more than ever, LEAs will need support in accelerating learning and supporting students’ well-being.
- Conduct a cross-sector survey of educators, students, and families physical and mental well-being, opportunities to learn, and contextualize data regarding connectivity, access to in-person instruction, and type of remote instruction this spring and throughout the recovery period to begin the process of reimagining public education in DC.
- Anticipate barriers and overcome them so that PARCC can be successfully administered in the spring of school year 2021-2022.
OSSE must execute a thoughtful contingency plan, should one be necessary
We urge OSSE to execute a thoughtful contingency plan to administer statewide summative assessments in the event that its waiver request is rejected by the US Department of Education (USED), as has been the case for the Georgia, New York, and South Carolina State Education Departments. OSSE must consider:
- Providing clear, transparent, and timely guidance to LEAs, parents/guardians, and students so everyone can adequately prepare for testing.
- Administering statewide summative assessments in the fall so that students, families, and educators can use the spring and summer to focus on implementing learning loss intervention and summer enrichment programming.
- Pairing down the exam to ensure feasible implementation and maximize in-person learning time, while offering high-quality, fair, reliable, and comparable results to include the following:
- Reducing the exam to 45-60 minutes, as was already being planned;
- Testing students in grades 3, 5 and 7 in the English Language Arts and grades 4, 6 and 8 in the Math with 9th and 11th grade assessments of PSAT and SAT continuing, and waiving the science exam; and/or
- Offering remote administration, as was originally contemplated in December.
- Waiving accountability components in the fall due to the challenges of the coronavirus pandemic. However, this does not mean waiving transparency and public reporting of data, nor does it mean waiving supports and interventions from the most recent school identifications.
Thank you for allowing us to submit a public comment about these critically important issues of racial equity.
Education Reform Now DC
 Council Office of Racial Equity. Source: https://www.dcracialequity.org/equity-term-glossary
 February 16, 2021. Education Reform Now DC. “New Poll Finds DC Parents Overwhelmingly Support Designating Emergency Funds to Limit Learning Loss.” Source: https://edreformnow.org/dc/new-poll-finds-dc-parents-overwhelmingly-support-designating-emergency-funds-to-limit-learning-loss/
 January 22, 2021. Education Reform Now DC. “ERN DC Submits Comments on Annual Assessment Waivers.” Source: https://edreformnow.org/dc/ern-dc-submits-comments-on-annual-assessment-waivers/
 December 2020. Empower K12. “COVID-19’s Impact on Student Achievement and Academic Growth in DC.” Source: https://www.empowerk12.org/research-source/covid-impact-achievement-dc
 March 26, 2021. Letter from USED regarding the Georgia Department of Education’s ESSA waiver request. Source: https://oese.ed.gov/files/2021/03/GA-assessment-response-letter-POST.pdf
 February 27, 2021. “U.S. Department of Education denies NY request to skip tests” Source: https://www.adirondackdailyenterprise.com/news/local-news/2021/02/u-s-department-of-education-denies-ny-request-to-skip-tests/
 March 26, 2021. Letter from USED regarding the South Carolina Department of Education’s ESSA waiver request. Source: https://oese.ed.gov/files/2021/03/SC-assessment-response-letter-POST.pdf
 March 26, 2021. Letter from USED regarding the Georgia Department of Education’s ESSA waiver request. Source: https://www.cde.state.co.us/assessment/20210326federalwaiverletter